ENGINEERING ANALYSIS CLOSING REPORT

SUBJECT: High-pressure fuel pump (HPFP) failure resulting in engine stall while driving.

EA No.: EA11-003 Date Opened: 7-Feb-2011 Date Closed: 27-Mar-2015

BASIS: On August 26, 2010, the Office of Defects Investigation (ODI) opened Preliminary
Evaluation PE10-034 to investigate seven complaints alleging incidents of engine stall while
driving in model year (MY) 2009 Volkswagen Jetta vehicles equipped with Volkswagen 2.0L TDI
Clean Diesel engines.

ODI upgraded the investigation to an Engineering Analysis on February 7, 2011, based on 160
complaints to ODI and Volkswagen involving HPFP failures in MY 2009 through 2010
Volkswagen Jetta and Golf and Audi A3 TDI vehicles and questions regarding fuel sample results
provided by Volkswagen as part of its response to PE10-034. During EA11-003, ODI analyzed
design information, field experience and test data for MY 2009 through 2012 Volkswagen Jetta,
Golf and Touareg and Audi A3 and Q7 vehicles equipped with TDI engines (Figure 1).

Figure 1. Subject TDI Vehicles, Clockwise from Upper Left: Volkswagen

Jetta Sedan, Jetta SportWagen, Golf (4 door) and Touareg; Audi A3 and Q7.

When PE10-034 was opened, ODI had not identified a specific fuel system component responsible
for the complaints of engine stall in the MY 2009 Jetta vehicles. As a result, ODI broadly examined
complaints of engine stall related to fuel system failure in the MY 2009 Jetta vehicles and sent an
information request letter to Volkswagen defining the alleged defect as engine stalling and/or loss
of motive power and the subject component as all TDI Clean Diesel fuel system components.
Volkswagens response to ODIs information request identified the HPFP as the primary cause of
customer concerns with stalling and loss of power related to the fuel system in MY 2009 Jetta TDI
EA11-003 Closing Report Page | 2

vehicles. Volkswagen further indicated that, apart from a limited number of failures related to
manufacturing process issues in early production vehicles, HPFP failures could be attributed to
vehicle operation with gasoline contaminated diesel fuel.

Volkswagen cited results from field tests performed on fuel samples taken from 43 vehicles which
had experienced HPFP failures in August and September 2010. According to Volkswagen, the
samples from 37 of the vehicles clearly showed average contamination of 8.5% gasoline in the
diesel fuel. However, ODIs review of the test results provided by Volkswagen determined that
the average contamination for the 37 vehicles was actually 0.85% based on the data provided.1
Based on questions regarding Volkswagens fuel test results and complaints alleging stalls caused
by HPFP failure with no prior misfuel, ODI upgraded the investigation to an Engineering Analysis.

DESCRIPTION OF SYSTEM: The subject vehicles are equipped with Volkswagens 2.0L 4-
cylinder and 3.0L 6-cylinder TDI Clean Diesel engines. Schematics of the fuel injections systems
are shown in Figures A1 and A2 in the Appendix. The HPFP supplies fuel pressure and flow
required for the Bosch common-rail piezo injection system (Figure 2). The engine control module
(ECM) manages fuel pressure by actuating the Fuel Pressure Regulator Valve, the Fuel Metering
Valve, or both, depending on operating conditions.

Figure 2. High Pressure Fuel Pump and Fuel Rail Assembly (2.0L 4-Cylinder Engine, CP4.1 Pump).

The subject HPFPs are Bosch tappet type pumps with a roller/cam drivetrain (Figure 3). The
pumps were designed with an Anti-Wear Package, including enhanced roller and roller end
coatings, for use with ultra-low sulfur diesel fuel sold in the United States2. Schematics of the
HPFP showing the internal components and flow path are provided in Figures A3 and A4. If the
pressure commanded by the ECM cannot be reached, system diagnostics will set a Rail Pressure
Control fault (e.g., DTC P0087 Fuel Rail/System Pressure- Too Low), which results in the Glow
Plug Light flashing and a transition to Limp Home operating mode with reduced fuel pressure.
1
The samples from only one vehicle showed evidence of potential gasoline contamination, with test results indicating
approximately 10.6% gasoline. The other 36 vehicles cited by Volkswagen averaged 0.58% gasoline.
2
ASTM D975 Grade No. 2-D S15 diesel fuel.
EA11-003 Closing Report Page | 3

Figure 3. HPFP Components.

SUBJECT VEHICLES: Volkswagen produced just under a quarter million subject vehicles.
Table 1 provides a breakdown of vehicles built by engine/pump, model and model year.3
Engine/ Model Year
HPFP Model 2009 2010 2011 2012 Total
Jetta 37,889 53,088 42,477 51,538 184,992
2.0L/ Golf -- 4,446 9,068 11,231 24,745
CP4.1 Audi A3 -- 2,180 3,791 3,865 9,836
Total 37,889 59,714 55,336 66,634 219,573
Touareg 833 1,771 2,454 5,500 10,558
3.0L/
Audi Q7 1,121 2,459 4,152 3,416 11,148
CP4.2
Total 1,954 4,230 6,606 8,916 21,706
Total 39,843 63,944 61,942 75,550 241,279
Table 1. Subject Vehicle Production, by Engine/Pump, Model and Model Year.

PROBLEM EXPERIENCE: A summary of field data related to the alleged defect is provided in
Table 2. All Volkswagen data in this report is through October 12, 2012, unless otherwise noted.
The incidents counted by ODI in Table 2 exclude, to the extent possible based on NHTSA analysis
of available records, HPFP replacements that did not involve drivetrain failure, HPFP failures that
did not involve a stall claim, and incidents resulting from misfueling with gasoline.

Field Data Source

Category Type ODI VW Total
Incident Consumer complaints 178 100 251
reports Field reports - 557 557
Total reports (unique VINs) 178 562 713
Repair records Warranty claims - 623 623
Total (unique VINs) 178 1,093 1,255
Table 2. Field Data Summary (totals are for unique vehicles, excluding duplicates).

3
In MY 2013 Volkswagen implemented misfuel guard protection in all vehicles equipped with CP4.1 and CP4.2
injection pumps, including certain Volkswagen Passat and Beetle vehicles equipped with 2.0L TDI engines. For the
subject vehicles, only the MY 2009-2012 Audi Q7 vehicles were built with misfuel protection devices in the filler neck.
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DESIGN CHANGES: Tables 3 and 4 summarize the design histories related to drivetrain
components in the CP4.1 and CP4.2 pumps used in the subject vehicles.

Date RP# Change Description Reason for Change

SOP RP0 HPFP with Anti Wear Package (AWP) - Adaptation to US market low lubricity
C-Coating, reduced plunger clearance diesel fuel (RP0)
May 2009 Change of carbon coating at roller Increase of robustness, eliminate
blemishes on roller surface
Nov 2010 RP1 Changed carbon coating of roller and roller shoe, Improvements against off-spec fuel in
reduced radial roller clearance, and added fuel critical foreign markets (RP1)
suction valve strainer
Nov 2011 RP1+ Changed carbon coating of roller and roller shoe Further improvements against off-spec
and reduced radial tappet clearance fuel in fuel-critical foreign markets
(RP1+)
Nov 2012 Increased wire diameter of metering unit mesh Improve resistance to strainer
strainer deformation
Table 3. Design History, CP4.1 Pump.

Date RP# Change Description Reason for Change

SOP RP0 HPFP with Anti Wear Package (AWP) - Adaptation to US market low lubricity
C-Coating, reduced plunger clearance diesel fuel (RP0)
May 2009 Change of carbon coating at roller Increase of robustness, eliminate
blemishes on roller surface
Apr 2010 RP1 Changed carbon coating of roller and roller shoe, Improvements against off-spec fuel in
reduced radial roller clearance, and added fuel critical foreign markets (RP1)
suction valve strainer
Nov 2010 RP2 Inlet & outlet of HPFP "swapped" and early Improve cooling diesel oil flow,
activation of fuel supply pump robustness improvement (RP2)
Nov 2010 Acoustic improved vent in the backflow Acoustic improved vent in the backflow
Nov 2012 Relocation of the overflow valve to the pump Optimization of the de-airing
outlet
Table 4. Design History, CP4.2 Pump.

VOLKSWAGENS ASSESSMENT: Volkswagen has not identified any design or manufacturing

defects in the subject TDI Clean Diesel pumps and has stated that the subject pumps were designed,
tested and approved for use in the United States market, with substantial design margins for fuels
that are out of specification. Volkswagen believes that misfueling with gasoline is the primary
cause of HPFP drivetrain failures in the field. The company does not believe that HPFP drivetrain
failure is likely to result in engine stall and, in incidents in which stalls do occur; they are preceded
by multiple obvious symptoms associated with reduced engine fuel rail pressure and poor engine
performance. Through December 2014, Volkswagen was not aware of any crashes or injuries
related to HPFP failures in the subject vehicles.
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VOLKSWAGEN FIELD ACTIONS: Volkswagen has taken several actions to address concerns
with misfueling the subject vehicles, starting with technical bulletins issued to dealers in the Spring
of 2010 with instructions for diagnosing and addressing use of incorrect fuel, a Diesel Only
customer information campaign, and service campaigns to install devices in the fuel filler neck to
prevent misfuel with gasoline.

Misfuel bulletins. On May 17, 2010, Audi issued technical service bulletin, TB A011008
2023360-1, to address concerns with engine performance, drivability and/or fuel delivery that may
be caused by contaminated or incorrect fuel in MY 2010 A3 vehicles with 2.0L TDI engines and
MY 2009-10 Q7 vehicles with 3.0L TDI engines. On June 8, 2010, Volkswagen issued TB
V011011 2023624 to address similar concerns in MY 2009 through 2010 Jetta and MY 2010 Golf
vehicles equipped with 2.0L TDI engines and MY 2009 through 2010 Touareg vehicles equipped
with 3.0L TDI engines.

The bulletins listed multiple symptoms associated with contaminated or incorrect fuel, including
malfunction indicator lamp (MIL) illumination, diagnostic trouble code P0087 (Rail fuel pressure
too low), excess rattling noise from the engine (diesel clatter), no start or hard starting, loss of
power while driving , and rust or metal debris found in the fuel system (Figure 4).

Figure 4. Examples of metal debris (left) and rust (right) in fuel filter housing inspection provided in Volkswagen and
Audi service bulletins.

The bulletins identified water ingress into service station holding tanks, errors in fuel transport and
incorrect fuel dispensed into the vehicle by customers or service station employees (i.e., misfuel) as
possible causes of fuel contamination and indicated that fuel system damage incurred by use of
fuel not complying with ASTM-D-975 Grade 2 S15 (B5 or less biodiesel content) standards would
not be covered under warranty.

Diesel Only advisory. On July 10, 2012, Volkswagen initiated a Diesel Only customer
advisory campaign, mailing letters to owners of subject vehicles with warnings against misfueling
with gasoline. Volkswagen provided warning labels for customers to place in the area of the
refueling door and cap (Figure 5), reminding operators to refuel with diesel fuel and that even
small amounts of gasoline can cause engine damage.
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Figure 5. Volkswagen Diesel Only customer advisory warning labels.

Misfuel Guard campaign. About 10 months later, on May 21, 2013, Volkswagen launched
Service Action Campaigns 20T8 (Volkswagen Jetta and Golf) and 20U3 (Audi A3) to contact
owners and provide free installation of misfuel guard devices in the filler necks of subject vehicles
with the 2.0L engines (Figures 6a and 6b). The vehicles with 3.0L engines were not included in the
campaign because the Audi Q7 vehicles already had misfuel protection devices in the original
vehicle design and the filler neck of the Volkswagen Touareg vehicles would not accommodate the
addition of a misfuel guard device.

Figure 6a. Service Action Campaign kit: 1Spring loaded flap Figure 6b. Campaign kit installed in filler neck.
insert, 2Fuel filler lockout mechanism, 3Plastic retaining ring,
4Replacement fuel cap with tether, and 5Mounting pin for
fuel cap tether.

By November 2014, Volkswagen reported campaign completion in approximately 69 percent of the

subject vehicles with 2.0L engines. Table 5 provides a breakdown of campaign completion rates by
model and model year through early November 2014.
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Model Year
Campaign Model 2009 2010 2011 2012 Total
Jetta 58% 66% 69% 76% 68%
20T8
Golf - 62% 68% 77% 71%
20U3 A3 - 80% 82% 88% 84%
Total 58% 66% 70% 77% 69%
Table 5. Completion Rates through 11/14/2013 for Volkswagen Service Campaigns.

Metering valve inspection bulletins. In an effort to reduce unnecessary pump replacements, in

March 2014 Volkswagen issued Technical Service Bulletins 2036656 (Volkswagen) and 2036668
(Audi) to change the requirements for replacing the HPFP when diagnosing driveability or engine
stall complaints involving symptoms of MIL on, rough running, no start or fuel rail pressure
diagnostic trouble codes (DTC P0087 Fuel Rail/System Pressure- Too Low, DTC P0088 Fuel
Rail/System Pressure Too High, or DTC P0191 Fuel Rail Pressure Sensor A Circuit
Range/Performance).. The bulletin eliminates the requirement to replace the pump following
removal of the N290 metering valve to inspect for metal particles/debris if the inspection results are
negative (Figure 7).

Figure 7. Fuel metering valve and valve bore with metal particles (A);
and without metal particles (B).

FIELD DATA ANALYSIS: ODI analyzed complaint, field return and warranty data to assess
failure rates and trends associated with HPFP drivetrain failure and resulting engine stall while
driving incidents. To the extent possible, ODI excluded incidents in which operator misfueling was
clearly the cause of the pump replacement.

VRTC Review Process. ODIs data analysis was performed after an extensive review process by
NHTSAs Vehicle Research and Test Center (VRTC) in East Liberty, Ohio. VRTC assisted ODI in
reviewing field data, compiling and managing a large database of over 6,000 field incidents,
EA11-003 Closing Report Page | 8

reviewing engineering documents and other technical information provided by Volkswagen and
Bosch, consulting with test laboratories and other independent experts in diesel fuel
properties/testing, coordinating the collection and testing of diesel fuel samples from select samples
of incident vehicles, and conducting tests to evaluate various misfuel evaluation methods used by
Volkswagen dealer personnel.

ODI analyzed the VRTC database and data provided by Volkswagen to assess rates of pump
drivetrain failures and related stall incidents by production date and design level. In addition, ODI
analyzed fuel sampling and pump field return analysis data to evaluate Volkswagens assessment
that misfueling with gasoline was the primary cause for incidents of HPFP drivetrain failures in the
subject vehicles.

Failure Rate Analysis. VRTCs analysis of data submitted by Volkswagen through early October
2012 identified 3,932 incidents of HPFP drivetrain failures that were not associated with an
admitted misfuel or fuel test results indicating a misfuel. The rates by pump and vehicle model are
shown in Table 6.

Vehicle HPFP Failure Exposure

Engine/ Vehicles Exposure Drivetrain Rate Adj Rate
HPFP Model Produced (Veh Yrs) Failures (IPTV) (IPTVY)
Jetta 184,992 356,154 3,178 17.2 8.9
2.0L/ Golf (A6) 24,745 30,096 272 11.0 9.0
CP4.1 Audi A3 9,836 15,069 155 15.8 10.3
Total 219,573 401,319 3,605 16.4 9.0
Touareg 10,558 13,593 123 11.6 9.1
3.0L/
Audi Q7 11,148 19,871 204 18.3 10.3
CP4.2
Total 21,706 33,464 327 15.1 9.8
Total 241,279 434,783 3,932 16.3 9.0
Table 6. HPFP Drivetrain Failure Rates by Engine/Pump and Vehicle Model.

Analysis of all data sources identified 1,255 incidents related to the alleged defect, engine stall
resulting from HPFP drivetrain failure that did not involve evidence of misfueling (Table 7). The
stalling data is a subset of HPFP drivetrain failure counts in Table 6, which also include incidents
involving allegations of no start, driveability and warning lamp illumination symptoms, as well as
many in which the symptoms and consequences of the failure were not known.

After adjusting for exposure, stalling rates are similar for each of the subject models ranging from
2.36 to 3.24 incidents per thousand vehicle years (IPTVY). The overall exposure adjusted rate is
2.89 IPTVY, which would result in a stalling rate of approximately 0.9 percent at 3 years in service.
There have been no confirmed crashes, injuries or fatalities related to the alleged defect.
EA11-003 Closing Report Page | 9

Vehicle Stalling Exposure

Engine/ Vehicles Exposure Stalling Rate Adj Rate
HPFP Model Produced (Veh Yrs) Incidents (IPTV) (IPTVY)
Jetta 184,992 356,154 1,032 5.6 2.9
2.0L/ Golf (A6) 24,745 30,096 71 2.9 2.4
CP4.1 Audi A3 9,836 15,069 48 4.9 3.2
Total 219,573 401,319 1,151 5.2 2.9
Touareg 10,558 13,593 44 4.2 3.2
3.0L/
Audi Q7 11,148 19,871 60 5.4 3.0
CP4.2
Total 21,706 33,464 104 4.8 3.1
Total 241,279 434,783 1,255 5.2 2.9
Table 7. HPFP Drivetrain Failure Engine Stall Rates by Engine/Pump and Vehicle Model.

Table 8 provides a breakdown of misfuel event counts and rates by engine/pump and model. The
data show a clear difference between the Audi Q7, which was sold with a misfuel protection device
in the filler neck, and the rest of the subject vehicles which were not built with misfuel protection
devices. The Q7 exposure adjusted rate of 0.25 incidents per thousand vehicle years is almost an
order of magnitude lower than the combined rate for the remaining subject vehicles (2.40 IPTVY).
Additional analysis by manufacturing date and pump design level is provided in the analysis section
of this report. As previously noted, analysis of failures by model and engine/pump did not find any
significant differences in field experience, apart from lower misfuel rates for the Audi Q7 vehicles
with misfuel prevention devices included since the MY 2009 launch.

Vehicle Misfuel Exposure

Engine/ Vehicles Exposure Rate Adj Rate
HPFP Model Produced (Veh-Yrs) Misfuels (IPTV) (IPTVY)
Jetta 184,992 356,154 850 4.6 2.4
2.0L/ Golf (A6) 24,745 30,096 50 2.0 1.7
CP4.1 Audi A3 9,836 15,069 54 5.5 3.6
Total 219,573 401,319 954 4.3 2.4
Touareg 10,558 13,593 41 3.9 3.0
3.0L/
Audi Q7 11,148 19,871 5 0.4 0.2
CP4.2
Total 21,706 33,464 46 2.1 1.4
Total 241,279 434,783 1,000 4.1 2.3
Table 8. Misfuel Rates by Engine/Pump and Vehicle Model.

Analysis of HPFP drivetrain failures and related stalls by month of production shows elevated rates
in the early production ramp-up period for the Jetta vehicles (Figures A5 and A6). No obvious
changes in field experience corresponding with drivetrain design changes are evident, although the
data was limited for the most recent design release when this data was captured in late 2012.

Design level. Analysis of HPFP drivetrain failure and related stalling rates by time in service for
each of the three design levels for the CP4.2 pumps shows slightly higher rates for the RP1 design
for HPFP drivetrain failures (Figure A7), but no significant difference when filtered for engine stall
EA11-003 Closing Report Page | 10

(Figure A8). In a November 2014 review with ODI, Volkswagen indicated that its age-adjusted
analysis of updated field data, including statistical forecast modeling of failure rates by time-in-
service, found minimal differences in pump performance by design level.

Vehicle testing. Volkswagen conducted vehicle testing with varying amounts of gasoline
misfueling to study the effects on engine performance and HPFP wear. The tests showed that
increased levels of gasoline will lead to driveability symptoms, such as engine stumbling, stuttering,
misfiring or rough running. According to Volkswagen, these symptoms start to become noticeable
at levels of gasoline misfueling of 50 percent. At levels of 80 percent4 and above, Volkswagen
indicated that driveability issues worsen until the diesel engine will no longer run due to the
interruption of the combustion process. At very high levels of misfueling (80-85%), test vehicles
exhibited obvious knocking noise within a few seconds after starting the vehicle and showed a
significant reduction in engine response and transition to limp mode operation in less than a mile
after attempting to accelerate to highway speeds. No performance problems were observed in 378
miles of test driving a vehicle with 5% gasoline added to the diesel fuel and Volkswagen has
indicated that operation with small amounts of gasoline contamination should have no effect on
HPFP durability. No damage to the HPFPs were observed by Volkswagen after misfuel tests with
either low or high amounts of gasoline misfueling.

Pump failure effects. ODI evaluated the effects of HPFP drivetrain failure on engine performance
by: 1) reviewing Volkswagens descriptions of the failure mechanism and effects; 2) analyzing ODI
complaint narratives combined with follow-up interviews, when necessary; 3) analyzing diagnostic
data retrieved by Volkswagen from some ODI complaint vehicles; and 4) reviewing the results of
Volkswagen testing of a vehicle with a pre-damaged pump roller.5

According to Volkswagen, drivetrain wear results in gradual reductions in fuel pressure due to
decreased pump plunger displacement. In addition, as wear progresses metal is abraded from
drivetrain surfaces forming small flakes that are circulated throughout the fuel system. Particles
caught in the metering unit strainer cause a pressure drop, which results in a fault code and warning
light. Volkswagen states that the rate of wear depends on the properties of fuel being used as well
as pump load conditions. Several of the pump failures in parts returned to ODI, or documented
during inspections by Bosch or by some consumers, displayed failures caused by rollers rotating 90
degrees relative to the cam, resulting in a distinct abrasive wear pattern in the center of the cam.
Figure 8 shows the Bosch self-stabilizing design and drivetrain damage resulting from roller
rotation in an ODI complaint vehicle that reported experiencing a sudden decrease in engine power
resulting in speed dropping from 70 mph to 50 mph, as the vehicle entered limp mode less than a
minute after the engine light and then glow plug lamp illuminated (VOQ 10354434).

4
Volkswagen indicated that a fuel tank mixture of 80% gasoline and 20% diesel would result from refueling with
gasoline shortly after the low fuel warning light has illuminated.
5
As previously noted, Volkswagen was not able
EA11-003 Closing Report Page | 11

Piston
Roller wear
Spring

Shoe

Roller

Cam Cam wear

Figure 8. Bosch self-stabilizing roller (left). Roller and cam damage resulting from
rotation of the roller; MY 2009 Jetta, RP0 pump, 06/08 vehicle build (right).

Volkswagen provided ODI with Diagnostic Fault Log data from 121 ODI complaint vehicles
alleging HPFP failures resulting in engine stall while driving. The diagnostic data shows time
and/or mileage travelled between diagnostic trouble codes logged in memory. ODIs analysis of
these complaints identified 85 alleging stall while driving, including 9 (10.6%) alleging that the stall
occurred suddenly with no warning. The Diagnostic Fault Log data for these vehicles indicated that
warning symptoms (DTC P0087, glow plug light, chime and limp mode) were available for all 85
(100%) and that the symptoms were present for at least one mile of driving in at least 58 (68.2%) of
the vehicles, including 5 (55.6%) of the allegations of sudden failure; for over 5 miles in at least 34
(40.0) of the vehicles, including 4 (44.4%) of the allegations of sudden failure; and for over 60
miles in 10 (11.8%) of the vehicles, including 1 (11.1%) of the allegations of sudden failure.

A Volkswagen test of a vehicle with a flat spot machined onto the roller of the HPFP drivetrain was
able to reproduce extended operation in limp mode. After a 23 minute warm-up at idle, this vehicle
entered limp mode (with warning light) when initially accelerating to 50 mph and continued to
operate in limp mode for another 43 minutes (36 miles) before the test was suspended.

FUEL TESTING

Initial VW field testing (2010). In its December 1, 2010 response to ODIs information request
letter for PE10-034, Volkswagen provided data from its initial efforts to test fuel samples from
vehicles repaired for HPFP failures. Volkswagen decided to purchase specific testing equipment
in August 2010 for precise and timely identification of fuel contamination for the workshops
without the need for a time consuming analysis in a testing laboratory.6 Volkswagen provided this
data in a table showing the content of gasoline, biodiesel and water in parts per million (ppm) for 3
measurements per sample. Volkswagen summarized the test data as follows:

6
Volkswagen purchased Integrated Portable Analyzer for Lubrication (iPAL) test devices for conducting early attempts
at field testing of fuel samples. The iPAL testers are described in product literature as an extremely small mid-IR
fingerprint region spectrometer.
EA11-003 Closing Report Page | 12

The table shows the results for 49 vehicles samples as follows:

In 4 cases the customer stated or admitted to have used gasoline instead of diesel
In 2 instances gasoline was used by mistake at a dealership sales department or during
pre-delivery inspection
In 43 cases, a sample was taken and analyzed from the fuel tank of the affected vehicle
Only 6 samples showed no or negligible amounts of gasoline in the sample, while one
showed approximately 2.5% water in the fuel
The remaining 37 samples clearly showed average contamination of 8.5% gasoline in the
diesel fuel

In summary, nearly 90% of the vehicles evidenced gasoline contaminated diesel fuel to be the
cause of the failure.

Examination of the data provided by Volkswagen determined that the average contamination of
8.5% gasoline in the 37 vehicles with the highest measured gasoline content was a miscalculation
and the actual average for those vehicles was 0.85%. For the 43 vehicles with fuel test data
provided, 1 vehicle showed an average gasoline content of approximately 10.6%, 4 samples were
between 1.11% and 1.51%, and the remaining 38 were all less than 1.0%. These results did not
point to gasoline contamination as a cause of fuel pump failures in those vehicles, which was a
factor in ODIs decision to upgrade the investigation to an Engineering Analysis in February 2011.
Volkswagen discontinued its use of iPAL equipment as of September 30, 2010 after determining
that the devices did not meet its requirements. In April 2011, Volkswagen began collecting fuel
samples from vehicles serviced for fuel system concerns for testing by a laboratory.7

VW Study (2011-2014). In March 2011, shortly after EA11-003 was opened, Volkswagen initiated
a study (Workshop Program) to collect HPFPs and fuel samples from incident vehicles and to
study properties of fuel sampled from sets of diesel fuel stations and randomly selected subject
vehicles. Table 9 summarizes field and test data submitted by Volkswagen in EA11-003, including
the counts for VWs classification of incidents for misfuel and engine stall8.

Incident Data
(complaints, field reports, Fuel Returned
claims, lawsuits, warranty) Sample Part Part
Submission Date Total Misfuels Stalls Analysis Analysis Sales
Original response 16-Dec-2011 1,443 510 206 431 102 1,873
Update #1 30-Nov-2012 6,147 2,102 1,232 827 301 6,057
Update #2 30-Oct-2013 6,6289 2,290 1,381 1,339 446 11,138
Update #3 17-Nov-2014 n/a n/a n/a 3,246 882 17,339
Table 9. Volkswagen Workshop Program Data Submission Summary.

7
Volkswagens fuel sample testing was performed by Inspectorate America Corporation IAC Linden.
8
Available complaint, field report and warranty records were analyzed by Volkswagen and VRTC to identify incidents
resulting from misfuel with gasoline and incidents that resulted in stall while driving.
9
Volkswagens second update provided additional incident data summaries and categorizations only for incidents in
which there was a fuel sample result or a returned pump analysis 8D report.
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Workshop Program fuel testing. As of October 2013, Volkswagen had submitted data to ODI
from fuel sample testing of 305 filling stations, 318 randomly selected vehicles, and 1,339 incident
vehicles. As previously noted, Volkswagen has identified misfueling with gasoline as the primary
cause of HPFP drivetrain failures in the subject vehicles. Volkswagen indicated that viscosity was
the best indicator of gross misfueling (Figure 9) and also a critical fuel property for maintaining
HPFP drivetrain integrity.

ASTM D975
No. 2-D S15
minimum
specification:
1.9 cSt

Figure 9. Volkswagen Viscosity Exhibit.

ODI analyzed the fuel test results for the control groups (fuel stations and random vehicles) and for
the incident vehicles. The incident vehicle test results were analyzed separately for incidents
classified by Volkswagen and misfuels and those in which misfuel was not indicated. ODI also
compared misfuel with non-misfuel incidents based upon whether misfuel was indicated in the test
results10.
Fuel Random Misfuel by VW Misfuel by Fuel
station vehicle Classification Sample Testing6
Fuel property survey survey Yes No Yes No
Total samples 305 318 456 881 221 1,116
Kinematic viscosity < 1.9 cSt 0.7% 0.0% 50% 0.5% 100% 1.0%
Flash point 52C 9.5% 6.9% 63% 4.5% 100% 9.5%
Biodiesel > 5% 9.5% 9.1% 12% 6.1% 5.0% 8.7%
Water > 0.05 1.0% 1.3% 3.5% 1.0% 4.5% 1.3%
Lubricity wear scar > 520 m 6.2% 2.8% 10.5% 3.4% 8.1% 5.4%
Table 10. Fuel Sample Group Comparison, Percentage of Out of Specification Results.

Analysis of field data, fuel sample and returned part analysis data from Volkswagens workshop
program and part sales data has not found evidence that misfueling with gasoline is the cause of

10
Misfuel determined by fuel samples with: 1) kinematic viscosity 1.9 cSt; and 2) flash point ambient temperature.
EA11-003 Closing Report Page | 14

HPFP drivetrain failures in cases where the operator denies misfueling. Fuel samples from vehicles
in which misfueling was acknowledged in complaint or repair records showed significantly
different properties than samples from vehicles in which the operator denied misfueling (Table 10).

Viscosity test data for vehicles with pumps replaced in Volkswagens Workshop Program that were
not classified as acknowledged misfueling incidents are similar to the data from the two control
groups (Table 10 and Figure A9). The results for the vehicles Volkswagen classified as misfuels
were significantly different. The results also indicate that many of the vehicles Volkswagen
classified as misfuels did not show evidence of gasoline in the test data. The differences between
workshop misfuel and non-misfuel data sets are even more evident when the misfuel incidents are
determined by fuel test results (Table 10 and Figure A10).

Figures A11 and A12 provide comparisons of the fuel sample groups for other fuel properties of
interest, again showing that the workshop vehicles with no indication of misfuel were most similar
to the results observed in the fuel station and random vehicle control groups.

Returned part analysis. Volkswagen submitted information from laboratory inspections of 446
fuel pumps returned from the field as part of the workshop program11. Approximately 8 percent of
the 446 pumps examined in the Workshop Program were not the original pumps in the vehicles
based on comparison of pump and vehicle manufacture dates, indicating prior pump replacements
for those vehicles. Drivetrain failure was observed in slightly under half of the pumps examined and
a similar number of inspections found the pumps were still functional, with most of these
categorized as No Trouble Found. The earliest design level pumps (RP0) had the highest
percentage of drivetrain failures (66%) and the lowest percentage of functional pumps (30%).

Pump Design Level

RP1+/
Pump Failure Mode RP0 RP1 RP2 Total
Drivetrain failure 100 84 31 215
Other failure 5 6 9 20
NTF/functional 44 121 46 211
Total 149 211 86 446
% Drivetrain 67% 40% 36% 48%
% NTF/functional 30% 57% 54% 47%
Table 11. Pump Failure Modes by Design Level, Returned Part Analysis.

Deposits (e.g., gum, corrosion) were observed on the drivetrain components in approximately half
of the pumps with drivetrain failures (108 of 214)12 and the remaining drivetrain failures were
classified as mechanical/hydraulic faults, with no determination possible as to cause. In either
case, Volkswagen assessed the cause of failure as damage resulting from unsuitable fuel (i.e.,

11
The pump inspections were performed by the pump supplier, Bosch.
12
Ratios of deposits/corrosion observed in pumps with drivetrain failure were similar for each design level.
EA11-003 Closing Report Page | 15

misfuel per Volkswagens definition).13 Table 11 provides a summary of the pump inspection
results by pump design level. Table 11a in the Appendix provides this analysis for pumps from
vehicles that Volkswagen did not classify as misfuel incidents and Table 11b does the same for
pumps from vehicles Volkswagen did classify as misfuel incidents.

Approximately 45 percent (202 of 446) of the pumps with returned part analysis reports also had
fuel sample test results. Analysis of the pump failure modes by indication of misfuel found that
pumps from vehicles involved in misfuel incidents based on the fuel sample test results were not
likely to experience drivetrain failure (6%) and were likely to have no trouble found or be
functional (90%). Pumps from vehicles in which the test results did not show evidence of misfuel
had a much higher likelihood of drivetrain failure (64%). Table 12 provides a summary of pump
failure modes by misfuel group, as determined from fuel test results. Tables 12a-c in the Appendix
provide breakdowns for each pump design level.

All Pumps
No %
Pump Failure Mode Misfuel Misfuel Total Misfuel
Drivetrain failure 3 96 99 3%
Other failure 2 4 6 33%
NTF/functional 46 51 97 47%
Total 51 151 202 25%
% Drivetrain 6% 64% 49%
% NTF/functional 90% 34% 48%
Table 12. Pump Failure Mode by Fuel Sample Result, All Pumps.

Part sales. Analysis of HPFP part sales trends does not appear to show any influence from
Volkswagens implementation of misfuel prevention devices in production in MY 2013 starting in
the summer of 2012, from Volkswagens Diesel Only owner advisory program, from the more
recent service campaign to add such devices to most of the subject vehicles that were sold without
them, or from the revisions to repair procedures in early-2014 that were intended to eliminate the
requirement to replacement pumps that were not damaged simply because the metering valve had
been removed to inspect for metal particles. The part sales show a seasonal influence with sales
increasing in summer months each year and a progressively increasing rate of sales per total
vehicles in service (Figures A13 and A14).

Table 13 shows the basic reasons for HPFP replacement in the subject vehicles and the estimated
breakdown of pump replacements and failures based on part return and fuel sample analysis data
provided by Volkswagen.14 To the extent possible, ODIs investigation was limited to drivetrain

13
In a January 21, 2014 e-mail, Volkswagen indicated that results of laboratory analysis of the deposits/corrosion
determined that the typical causes are water, aged fuel, and fuel additives.
14
Estimated percentages are based on ODI analysis of Volkswagen field return and fuel sample test data (see Tables 12
and 13). It should be noted that Volkswagen field return analysis data is not necessarily a representative/random
sampling of all pump returns/replacements as the rate of samples with results consistent with gross misfueling with
EA11-003 Closing Report Page | 16

failures resulting in engine stall which are a subset of category F1. Most of these failures are not
associated with any evidence of a gross misfueling event. Failures resulting from fuel quality
issues, including factors Volkswagen identified as likely causes of deposits observed in pumps with
drivetrain failures, will not be prevented by the addition of misfuel guards.
Estimated Percentages
ODI Pump Pump
Reason Subcategory Code Failures Replacements
Drivetrain failure indicated by metal debris in F1 88.5% 46.6%
N290 metering valve with no indication of
significant gasoline misfuel in fuel sample testing
VW repair procedure for gasoline misfuels F2 3.0% 1.6%
Pump
resulting in pump drivetrain failure indicated by
failure
metal debris in metering valve (VW Scenario 3)
Other pump failures (e.g., metering valve, F3 8.5% 4.5%
pressure regulating valve, piston return spring,
check valve)
VW repair procedure for misfuel with gasoline P1 n/a 22.4%
followed by engine crank/start and no evidence of
Repair pump damage (Scenario 2)
procedure VW repair procedure requiring pump replacement P2 n/a 24.9%
when metering valve is removed to inspect for
metal debris (when no debris is found)
Table 13. HPFP Replacement Categories.

The continuing pump sales trend after Volkswagens various actions indicate that drivetrain failures
may be a higher percentage of total failure than shown in Table 13. HPFP drivetrain failure results
in contamination of the fuel system with metallic debris, so repair requires replacement of all or
most fuel system components (e.g., fuel rail, injectors, fuel tank, in-tank delivery pump, auxiliary
pump, fuel filter and fuel pipes) in addition to the failed HPFP and is very costly (frequently over
$10,000).

REASON FOR CLOSING: ODIs analysis of HPFP drivetrain failure incidents indicates that
most failures do not result in engine stall while driving and, when pump drivetrain failure does
result in stall while driving, it is usually preceded by numerous warning symptoms (e.g., glow plug
warning lamp, chime, limp mode, and driveability symptoms). The failure data for the subject
vehicles show relatively low stalling rates (less than one percent at three years in service) for each
of the pump designs used in the subject vehicles. There have been no reports of crashes, injuries or
fatalities related to the alleged defect. Based on these facts, this investigation is closed. The closing
of this investigation does not constitute a finding by NHTSA that a safety-related defect does not
exist. The agency will continue to monitor complaints and other information relating to the alleged
defect in the subject vehicles and take further action in the future if warranted.

gasoline (kinematic viscosity < 1.9 cSt and flash point below ambient temperature) was 52% higher in pump returns
with fuel sample results available (25.2%) than in the total set of fuel sample test results (16.6%).
EA11-003 Closing Report Page | 17

APPENDIX

Figure Description Page

A1 4-Cylinder Fuel System Schematic 19

A2 6-Cylinder Fuel System Schematic 19

A3 CP4.1 Pump Schematic 20

A4 CP4.1 Pump Schematic 20

A5 Cumulative Failure Rates by Build Month, HPFP Drivetrain Failures, 21

Excluding Known Misfuels (CP4.1 pumps)

A6 Cumulative Stall Rates, HPFP Drivetrain Failures, Excluding Known 21

Misfuels (CP4.1 pumps).

A7 Cumulative Rates by Months in Service and Design Level, HPFP 22

HPFP Drivetrain Failures, Excluding Known Misfuels (CP4.1 pumps)

A8 Cumulative Stall Rates by Months in Service and Design Level, HPFP 22

HPFP Drivetrain Failures, Excluding Known Misfuels (CP4.1 pumps)

A9 Volkswagen Fuel Viscosity Testing by Sample Group, Workshop Groups 23

Based on Volkswagen Assessment of Complaint & Field Report Reports

A10 Volkswagen Fuel Viscosity Testing by Sample Group, 23

Workshop Groups Based on Test Results

A11 Fuel property comparison, control groups vs disputed misfuel groups 24

A12 Fuel property comparison, control groups vs misfuel groups 24

A13 Part Sales Trend by Month Sold 25

A14 Cumulative Pump Sales Rates by Month 25

(Cumulative Pump Sales as Percentage of Cumulative Vehicles Sales)
EA11-003 Closing Report Page | 18

Table Description Page

11a Pump Failure Modes by Design Level from Returned Part Analysis, 26
for Incidents VW Did Not Classify as Misfuel from Complaint, Field
Report or Warranty Record

11b Pump Failure Modes by Design Level from Returned Part Analysis, 26
for Incidents VW Classified as Misfuel from Complaint, Field Report
or Warranty Record

12a Pump Failure Mode by Fuel Sample Result, RP0 Pumps 27

12b Pump Failure Mode by Fuel Sample Result, RP1 Pumps 27

12c Pump Failure Mode by Fuel Sample Result, RP1+/RP2 Pumps 27

EA11-003 Closing Report Page | 19

Figure A1. 4-Cylinder Fuel System Schematic.

Figure A2. 6-Cylinder Fuel System Schematic.

EA11-003 Closing Report Page | 20

Figure A3. CP4.1 Pump Schematic.

Figure A4. CP4.1 Pump Operation.

EA11-003 Closing Report Page | 21

Roller end coating

RP1 changes

RP1+ changes

Figure A5. Cumulative Failure Rates by Build Month, HPFP Drivetrain Failures,
Excluding Known Misfuels (CP4.1 pumps).

Roller end coating

RP1 changes
RP1+ changes

Figure A6. Cumulative Stall Rates, HPFP Drivetrain Failures,

Excluding Known Misfuels (CP4.1 pumps).
EA11-003 Closing Report Page | 22

Figure A7. Cumulative Rates by Months in Service and Design Level,

HPFP Drivetrain Failures, Excluding Known Misfuels (CP4.1 pumps).

Figure A8. Cumulative Stall Rates by Months in Service and Design Level,
HPFP Drivetrain Failures, Excluding Known Misfuels (CP4.1 pumps).
EA11-003 Closing Report Page | 23

ASTM D975 No. 2-D S15 max spec 4.1 cSt

ASTM D975 No. 2-D S15 min spec 1.9 cSt

Figure A9. Volkswagen Fuel Viscosity Testing by Sample Group, Workshop Groups Based on
Volkswagen Assessment of Complaint & Field Report Records.

ASTM D975 No. 2-D S15 max spec 4.1 cSt

ASTM D975 No. 2-D S15 min spec 1.9 cSt

Figure A10. Volkswagen Fuel Viscosity Testing by Sample Group, Workshop Groups Based on Test
Results (Misfuel determined by: Kinematic Viscosity < 1.9 cSt AND Flash Point amb temp).
EA11-003 Closing Report Page | 24

Figure A11. Fuel property out-of-specification results (%), control groups vs "no misfuel" groups.

Figure A12. Fuel property out-of-specification results (%), control groups vs misfuel groups.
EA11-003 Closing Report Page | 25

Figure A13. Part Sales Trend by Month Sold.

Figure A14. Cumulative Pump Sales Rates by Month

(Cumulative Pump Sales as Percentage of Cumulative Vehicles Sales).
EA11-003 Closing Report Page | 26

Pump Design Level

RP1+/
Pump Failure Mode RP0 RP1 RP2 Total
Drivetrain failure 91 67 24 182
Other failure 3 4 5 12
NTF/functional 27 37 26 90
Total 121 108 55 284
% Drivetrain 75% 62% 44% 64%
% NTF/functional 22% 34% 47% 32%
Table 11a. Pump Failure Modes by Design Level from Returned Part Analysis,
for Incidents VW Did Not Classify as Misfuel from Complaint, Field Report or Warranty Record.

Pump Design Level

RP1+/
Pump Failure Mode RP0 RP1 RP2 Total
Drivetrain failure 9 17 7 33
Other failure 2 2 4 8
NTF/functional 17 84 20 121
Total 28 103 31 162
% Drivetrain 32% 17% 23% 12%
% NTF/functional 61% 82% 65% 75%
Table 11b. Pump Failure Modes by Design Level from Returned Part Analysis,
for Incidents VW Classified as Misfuel from Complaint, Field Report or Warranty Record.
EA11-003 Closing Report Page | 27

RP0 Design Level

No %
Pump Failure Mode Misfuel Misfuel Total Misfuel
Drivetrain failure 2 22 24 8%
Other failure 1 0 1 100%
NTF/functional 10 3 13 77%
Total 13 25 38 34%
% Drivetrain 15% 88% 63%
% NTF/functional 77% 12% 34%
Table 12a. Pump Failure Mode by Fuel Sample Result, RP0 pumps.

RP1 Design Level

No %
Pump Failure Mode Misfuel Misfuel Total Misfuel
Drivetrain failure 1 58 59 2%
Other failure 0 2 2 0%
NTF/functional 34 28 62 55%
Total 35 88 123 28%
% Drivetrain 3% 66% 48%
% NTF/functional 97% 32% 50%
Table 12b. Pump Failure Mode by Fuel Sample Result, RP1 Pumps.

RP1+/RP2 Design Level

No %
Pump Failure Mode Misfuel Misfuel Total Misfuel
Drivetrain failure 0 16 16 0%
Other failure 1 2 3 33%
NTF/functional 2 20 22 9%
Total 3 38 41 7%
% Drivetrain 0% 39% 39%
% NTF/functional 67% 53% 54%
Table 12c. Pump Failure Mode by Fuel Sample Result, RP1+/RP2 Pumps.